CITY OF HILLSBORO

150 E. Main Street, Hillsboro Oregon 97123 Office: 503-615-6702

 Fax: 503-615-6595

Water Department

March 19, 2008

Bob McDonald

Project Lead

Bureau of Land Management

Tillamook Resource Area

4610 3rd St.

Tillamook, OR 97141

RE: Protest to the Roaring Creek Decision Rationale as they relate to the City of 

Hillsboro’s Slow Sand Filter Plant

Dear Mr. McDonald,

The City of Hillsboro Water Department submits this protest regarding the Roaring Creek Projects 

Decision and Decision Rationale. The City of Hillsboro Water Department submitted comments on the 

EA expressing concerns of inadequate drinking water protection. As indicated in those comments our 

Slow Sand Filtration Plant (SSFP) is extremely susceptible to turbidity events in the Upper Tualatin River 

Basin. 

The SSFP is located on the Tualatin River west of Haines Falls, approximately 1⁄2 mile downstream from 

the proposed density management treatment areas in section 29, and just over a mile from the nearest 

proposed road work. The SSFP is the sole water supply source for the community of Cherry Grove and 

the primary source for Dilley, LA Water Cooperative, and the City of Gaston. 

BLM’s proposed actions threaten to disrupt or severely degrade the capability of the plant to serve those 

communities. Due to the limited nature of the treatment process at the SSFP, it is very sensitive to 

additional sediment loads. The EA points out that the treatment plant has experienced high turbidity and 

nutrient problems in the past (page 57) yet no accommodating changes were made in the Decision 

Rationale [were no changes made or were there changes that just aren’t adequate to address high 

turbidity and nutrient problems]. The Water Department is concerned that implementation of the 

proposed actions could result in significant impacts to our drinking water supply. It is for these reasons 

that we are particularly concerned about the impacts the Roaring Creek project may have on 

sedimentation and turbidity. This sole drinking water source has not received sufficient management 

considerations.
We want to be clear that the Water Department is supportive of [or not opposed to] timber harvest that ensures full

protection of our public water supply sources that provide drinking water to the more than 300,000 Oregonians that we serve. 

We also recognize that BLM has a unique responsibility under the Oregon and California (O&C) Act to provide a sustainable 

supply of timber. However, In addition to sustainable production of timber, the of O&C Act mandates that timber be sold, cut, 

and removed “in conformity with the principal of sustained yield for the purpose of providing a permanent source of timber 

supply, protecting watersheds, regulating stream flow, and contributing to the economic stability of local communities and 

industries, and providing recreational facilities . . .(43 U.S.C. §1181a)”. Given potential impacts from roads and timber harvest 

we do not believe that BLM’s proposed decision adequately protects a watershed that is the sole water supply source for the 

community of Cherry Grove and the primary source for the communities of Dilley, LA Water Cooperative, and the City of Gaston.

Further, we believe that impacts to public water supply from BLM’s proposed actions will have adverse economic and 

destabilizing effects on local communities and industries served by Hillsboro’s Slow Sand Filter Plant. These mandated O&C 

Act requirements for protecting watersheds and contributing to the economic stability of communities have not been adequately

addressed by the proposed action, nor in the responses to our comments.

We also note the Clean Water Act and Safe Drinking Water Act are federal laws which require full protection of water quality and 

beneficial uses such as municipal water supply. The O&C Act does not obviate the need to meet these federal laws. 

In the EA’s scoping letters [whose letter(s)?] a comment was made that commercial harvest activities and 

road construction in municipal watersheds should be avoided. The BLM responded that no such 

municipal watersheds existed in the project area. Since this information is incorrect we are asking for a 

reconsideration of the proposed actions to increase protections to the City of Hillsboro’s municipal water 

supply source. 

Please respond to our additional questions about proposed treatements. What is the current relative 

density in riparian areas and upland areas in the harvest units? Will trees in the 60’ no cut zone count 

towards calculation of the post-treatment relative density targets for riparian areas? Why were proposed 

relative density targets chosen that will not maximize forest stand vigor and growth and canopy closure 

levels? 

Multiple-objective thinning research on Olympic National Forest has found that a relative density of 35 to 

50 maximizes forest stand vigor and growth. The relative density of mature stands inventoried in 

Washington State ranged from approximately 60 to 87 (see Study on Riparian Desired Future Condition 

Performance Targets for Forests and Fish Program 2004). BLM’s proposed action would result in stands 

with a relative density of 25on upland sites and 30 in riparian stands. While we understand that BLM 

wants to accelerate the growth of individual trees it is not clear how treatments would meet Aquatic 

Conservation Strategy (ACS) objectives 4 and 5 which focus on maintaining and restoring water quality 

and sediment regimes. Proposed ground based skidding on over half the area, new roads, and the level of 

tree removal do not support BLM’s affirmative findings for these two ACS objectives. We believe that 

the proposed harvest methods and intensity levels are not appropriate given the public water supply 

concerns. We suggest that post treatment relative density targets towards the high end of the range for

maximizing forest stand vigor and growth would be appropriate. We are not certain how this would relate 

to BLM’s basal area targets but note that the above referenced inventory of mature stands in Washington 

found mean basal area levels ranging from approximately 300 square feet/acre to 368 square feet/acre

depending on site productivity. Removal of no more than a third of the basal area on stands in BLM’s sale 

units would help maintain a higher canopy level and result in less ground disturbance. We would be 

agreeable to eliminating harvest and new roads on slopes above 50% in section 29 and on units where 

there are steep headwall areas or high to moderate erosion potential.
Sedimentation due to timber yarding, hauling and road construction and maintenance.

BLM’s argument that the only increase sediment will result from the removal of an existing culvert in 

Section 29 is not supported. We believe that the high level of ground based skidding, new road 

construction, and the relatively high level of tree removal will exacerbate sedimentation and stream 

turbidity which are already a periodic problem at the SSFP. We support planning operations during the 

summer season and agree that increased sedimentation will occur during the first rainfall event. However, 

the effects of topsoil disturbance, roads, reduced canopy levels, soil compaction, and disturbance of steep 

headwalls will be seen in subsequent winter seasons.

Review of analysis determining road construction affects on water quality.

BLM comments that any increases in sedimentation and turbidity would occur over a three year time 

period. Our municipal water supply must deliver water every hour of every day. The turbidity increases 

for three years will require major operational and maintenance adjustments by means of increasing staff 

time to monitor turbidity levels and the increased capital costs of filtration materials. 

As implied by the EA, road use alone causes increases in sedimentation. The mere presence of an 

improved road can increase the sedimentation delivery (Jones). We do acknowledge and support BLM 

efforts to decommission decaying roads. We object to BLM’s reluctance to acknowledge that even well 

constructed roads can increase sedimentation delivery, particularly in a watershed that provides such a 

sensitive municipal water supply source. 

Based on our discussions with the Oregon Department of Environmental Quality and the Environmental 

Protection Agency it is our understanding that other Oregon municipalities are dealing with high turbidity 

levels as a result of forest practices attributed to roads and harvest levels and methods. Water quality 

impacts from forest practices on private and State lands and management associated with other land uses 

makes a conservative approach on BLM lands even more important from a cumulative effects 

perspective.

City of Hillsboro coordination with BLM

The City of Hillsboro is very appreciative of the assurances BLM has made to keep our staff involved. 

We will be required to increase staff presence at the SSFP to track turbidity levels to prevent a total plant 

shut down. The COH Water Department requests to be informed of all pending land use activities 

including harvest, fertilizer and herbicide application.

Sedimentation

The Decision Rationale claims to accommodate the Upper Tualatin/Scoggins Creek Watershed analysis. 

According to this document a key water quality recommendation is to “expand the Best Management 

Practices to reduce sediment discharge to streams and revegetate eroding areas.” Sedimentation is 

impairing the biological function of the watershed (Upper Tualatin Watershed Analysis). The reduction of 

erosion and mass flow events is also a major management goal of the Upper Tualatin watershed analysis. 

It recommends increases in riparian vegetation to reduce erosion and filter pollutants.

Currently the BMPs for erosion reduction have not been adequately assessed for the Upper Tualatin basin

(watershed analysis). However, the NW Forest Plan Preliminary Assessment has shown that riparian 

reserves of this magnitude have been successful in maintaining watershed conditions. These riparian 

reserves are 180 feet along intermittent streams and 360 feet along fish bearing streams. We ask that the 

BLM consider increasing the riparian reserves to meet these NW Forest Plan requirements. It has been 

shown that an effective buffer width is 300ft for overland flows, but that sediment can be transported 
4500ft if channels are formed (Belt and O’Laughlin 1994). Given the steep topography and highly 

erodible soils we request an increased buffer width.

We ask that the BLM create BMPs to control erosion. BMPs and erosion control measures on roadsnewly constructed and decommissioned- and surrounding any harvest activities affecting the SSFP at least 

one year after operations. Coordinating the implementation of these BMPs with the COH is the best 

method. This has been successful in coordinating with private forestry operations adjacent to COH’s 

municipal water supply sources.

The limited buffer size proposed by the BLM is not congruent with the recommendations of either the 

watershed analysis, or the NW Forest Plan. We ask that the BLM aggressively consider increasing the 

size of the stream buffer width, especially in section 29.

Mass Wasting

Pg 64 of EA “Most of the eroded material in the upper Roaring Creek appears to originate from natural 

sources, mainly from deep-seated mass wasting.” Pg 49” A few additional, small fragile areas will 

probably be identified and removed upon closer examination during the timber sale layout” We implore 

the BLM to be overly cautious when selecting these areas especially in area 29. 

Additionally, all activities in riparian areas must not retard or prevent attainment of NW Forest Plan 

aquatic conservation strategy objectives. Including maintaining and restoring the sediment regime 

composed of timing, volume, rate and character of sediment input, storage and transport. We feel that the 

currently proposed actions put the soil at high risk for major alterations to the sediment regime and the 

increase of mass wasting events. 

Since, the primary interest is to increase the growth rate of individual tress the RD should be increased 

even further from 30 to a minimum of 35 or more agreeably to 50. An RD of this magnitude will 

minimize soil displacement and maximize precipitation interception. The proposed RD of 30 in this 

highly sensitive area is deemed inadequate in our opinion.

No-Harvest Areas

Riparian no harvest buffers may have yarding corridors cut through if necessary. Trees cut in the buffer 

will be left on site to augment CWD (Pg 25). Yarding corridors expected to be 12 feet wide and 150 feet 

apart.

Cumulative Impacts

In the past decade the Upper Tualatin watershed has been heavily logged by private industrial and nonindustrial owners. Combine these recent logging events with the planned BLM and ODF ones and it 

becomes obvious that the SSFP has been placed in a precarious environment.

Nonmarket values

Impacts to nonmarket values are not well described or quantified in the EA analysis. These values affect 

the economic well-being, health, and resiliency of these local communities served by the COH SSFP. 

Clean drinking water is a highly valued commodity produced by BLM lands. The valuable commodity of 

the clean drinking water entrusted to BLM’s hands of economic well-being, public health, and resiliency 

of these local communities. The increased value of the BLM’s fiduciary responsibility to protect the 

health, safety and welfare of the public would. 
Even if full SSFP shut down is not a direct result of the actions taken by BLM, even minor increased 

sedimentation loads will increase the operational and maintenance cost including staff time, filtration, 

monitoring

Protection measures

As administrators of the Clean Water Act, the DEQ regulates water protection measures. Although the 

State of Oregon does not have a water quality standards specifically for protection of municipal water 

sources (pg 57) a turbidity water quality standard does exist. Water quality standards not only include a 

numeric and narrative criteria, they also include designated beneficial uses which must be fully protected, 

and an anti-degradation policy. We note that municipal water supply is one of if not the most sensitive 

beneficial use which must be protected. All waters within Oregon regardless of whether they pass 

through public or private lands must not increase turbidity levels more than 10% of background levels. 

All BLM operations must meet this standard of the Aquatic Conservation Strategy. The SSFP closely 

monitors turbidity levels, should the level increase more than 10% the DEQ will be notified of the 

violation. Should turbidity levels become higher than 5 NTUs we will need to shut down the SSFP. 

Recommendations

Eliminate logging on slopes above 50% in section 29 [see earlier text for other areas].

Increase harvest buffer to meet NW Forest Plan standards, including 180ft buffers along

intermittent streams and 360ft buffers along fish bearing streams. Or at least 100 ft buffers along 

intermittent. [are you sure these aren’t the buffers proposed]

BMPs and erosion control measures on roads- newly constructed and decommissioned- and 

surrounding any harvest activities affecting the SSFP at least one year after operations. 

Minimize number and potential impact of corridors needed for operations within no harvest 

buffers and riparian reserves.

If considering no harvest buffer and/or riparian reserve within the RD calculation, then increase 

RD to 0.4. If these areas are not included in the RD calculation, then increase the RD to 0.35. [see earlier 

discussion]

Make sure recommendations are conistent with earlier text or change earlier text.

Please call if you have any questions at (503) 615-6585

Sincerely,

Kevin Hanway

Director, Water Department

City of Hillsboro

(503) 615-6585

kevinha@ci.hillsboro.or.us